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On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs. The suspended rulings had arguably required the distributing corporation and the spun-off corporation to each independently generate current revenue. This development is welcome news for life sciences, technology, and other research and development (R&D)-focused business organizations that did

In this Ropes & Gray podcast, Ben Simmons, an associate in the tax group, is joined by David Saltzman, a partner in the tax group, to discuss the recent Tax Court memorandum decision, Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue. This case involved a strategy designed to permit a U.S.

On September 25, 2018, the IRS announced that it is considering guidance on the treatment of spinoffs involving business ventures engaged in research and development for future profit. The announcement is of special interest to life sciences and other technology ventures actively engaged in R&D for new pharmaceutical, medical device or other technology-based products. In

In this Ropes & Gray podcast, tax associate Brandon Dunn is joined by tax partners Kat Gregor and David Saltzman to discuss one of the most notable tax decisions from the fourth quarter of 2017 and its implications for taxpayers, particularly multinational corporations. On September 29, 2017, in Chamber of Commerce of the United

On September 27, 2017, the White House and a group of congressional leaders, commonly referred to as the “Big Six”, released a joint framework for proposed tax reform. The framework sets out five goals: middle-class tax relief, simplifying tax returns for most Americans, business tax relief, ending incentives to shift jobs and capital overseas, and